Business and International Tax Blog

Sorting Out the Parallel Universes of Subpart F and GILTI Income Inclusions: The Unintended Collision With Respect to Deemed Sale of Controlled Foreign Corporation Stock[1]

By Jerald David August

The Tax Cuts and Jobs Act of 2017, P.L. 115-87 (TCJA), ^[2] enacted into law on December 22, 2017, introduced numerous reforms to international taxation which changes have already had a profound impact on tax planning for multinational business enterprises (MNEs) as well as domestic businesses engaged in foreign business ventures or investments.^[3]  The most significant reform enacted ...